As an additional basis for excluding burn testing of a home theater component, the court ruled that the party offering the expert failed to show that the testing conforms to reliable principles and methods.  The expert did not know the temperature or the amount of heat produced by the propane flame source that he used to ignite the exemplar.  He admitted that the propane source would not create the same amount of heat or temperature as the power source that he identified as the ignition source.  He kept no notes or contemporaneous records that could potentially show the soundness of his methodology.  The party offering the expert failed to satisfy its burden of demonstrating that the expert's testimony is based upon a reliable methodology.   

MMG Ins. Co. v. Samsung Electronics America, Inc.,  2013 WL 2444033 (D.NH 2013)